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HMRC internal manual

Enquiry Manual

HM Revenue & Customs
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Recalculating Profits: Tax Cases: Gamini Bus Co Ltd v Commissioner of Income Tax, Colombo 1952 AC571

The Revenue at the appeal hearing produced a list, anonymised, showing the expenditure on petrol and oil of seven other bus companies and the net profit on which these companies were assessed. This produced an average ratio of profits to expenditure on petrol and oil.

The tribunal accepted the document as evidence and the Privy Council held the list had been properly and fairly used and that there was no breach of confidentiality.